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BBP Compliance Checklist

Your quick-reference guide to bloodborne pathogen safety requirements. Print it. Post it in your studio. Use it daily.

Prepared by Chrys Young, RN, MSN-NP
Updated April 2026
Compliance OSHA 29 CFR 1910.1030

A note from Chrys Young, RN, MSN-NP — Board-Certified FNP & 30-Year Master Tattoo Artist I've been running this checklist in my own studio for over 20 years. It's not just about passing an inspection — it's about keeping your artists, your clients, and your reputation intact. Work through every item below, check it off as you go, and post this where your whole team can see it every single day.

Note: This checklist is a reference guide, not a substitute for formal BBP certification. Completing certification satisfies annual OSHA training requirements.

Compliance Checklist

🧼 Hand Hygiene

Wash hands before and after every procedure
Use liquid soap and warm water for at least 20 seconds. Scrub all surfaces: palms, backs, between fingers, under nails.
29 CFR 1910.1030(d)(2)
Use disposable gloves and change between every client
Single-use gloves must be discarded immediately after use. Never wash or re-use disposable gloves.
29 CFR 1910.1030(d)(3)
Wash hands immediately after removing gloves
Gloves are not a substitute for hand hygiene. Wash hands after every glove removal, even between clients.
OSHA Best Practice

💉 Sharps Handling & Disposal

Sharps containers at every workstation
Place puncture-resistant sharps containers within arm's reach of every workstation. Never set used needles aside to re-cap.
29 CFR 1910.1030(d)(4)(i)
Never recap needles — place directly in sharps container
Recapping is the leading cause of accidental needlesticks. Deposit used needles into the sharps container immediately after use.
29 CFR 1910.1030(d)(2)(vii)
Do not overfill sharps containers
Close and replace when ¾ full. Overfilled containers increase injury risk during transport and disposal.
Cal. HSC §118285
Arrange licensed medical waste pickup
Contract with a registered medical waste hauler for regular pickup. Keep manifests on file for at least 3 years.
Cal. HSC §118275

🧹 Surface Disinfection

Clean then disinfect all surfaces between clients
Two-step process: (1) remove organic matter with soap/water or EPA-registered detergent, then (2) apply EPA-registered hospital-grade disinfectant. Never skip step one.
29 CFR 1910.1030(d)(4)(ii)
Use surface barriers on equipment that cannot be disinfected
Barrier films (plastic wrap, disposable covers) on chair armrests, trays, and machines. Discard barriers between every client.
CDC Guidelines
Wet-cure or properly dispose of single-use supplies
Ink caps, disposable cups, barrier film, and other single-use items must be discarded after each client. Do not "quick wipe" and reuse.
CA Safe Body Art Act
Maintain equipment cleaning log
Record date, time, surface treated, and product used for end-of-day deep cleaning. Keep logs on file for at least 12 months.
Best Practice

🦺 Personal Protective Equipment (PPE)

Gloves available in all required sizes
Supply nitrile or latex gloves in S, M, L, and XL. Improperly sized gloves increase tearing and exposure risk.
29 CFR 1910.1030(d)(3)
Eye protection at every station
Splash-proof goggles or face shields within arm's reach. Blood and ink splatter are both occupational hazards.
29 CFR 1910.1030(d)(3)(i)
PPE stored separately from work area
Clean PPE stored in a designated area away from contaminated equipment. Do not store PPE in the same drawer as tattoo machines or ink.
Best Practice
PPE soiled with blood disposed of in regulated medical waste
Used gloves, gauze, and barriers with visible blood go in red biohazard bags — not regular trash.
Cal. HSC §118275

🚨 Exposure Incident Protocol

Exposure control plan posted and accessible
Written plan available to all staff at all times. Includes: steps to take after an exposure, reporting procedure, and post-exposure follow-up information.
29 CFR 1910.1030(d)(1)
First aid supplies accessible in the studio
Bandages, antiseptic, eye wash station, and emergency contact list in a clearly marked location. Check expiry dates monthly.
29 CFR 1910.1030(d)(2)
Report every exposure incident within 24 hours
Document: date/time, who was involved, the procedure, type of exposure, and actions taken. Report to employer and seek medical evaluation within 72 hours.
29 CFR 1910.1030(d)(2)(vii)
Post-exposure medical evaluation pathway documented
Know the nearest urgent care or occupational health clinic. Have the employer's written opinion template ready for the evaluating healthcare provider.
29 CFR 1910.1030(d)(2)(iii)

📋 Training & Annual Renewal

All staff trained annually on BBP protocols
OSHA requires initial training at hire and annual refresher training. Training records must be kept for 3 years — include date, trainer name, and content covered.
29 CFR 1910.1030(g)(2)
Training records on file for all current staff
Keep records for 3 years after the employee leaves. Each record should show completion date, trainer, and topics covered.
29 CFR 1910.1030(g)(2)(vii)
Hepatitis B vaccine offered to all at-risk staff
OSHA requires employers to offer the Hep B vaccine series at no cost to all employees with occupational exposure risk. Document declination if an employee refuses.
29 CFR 1910.1030(f)(2)
Exposure control plan reviewed and updated annually
Annual review must consider new safer medical devices, changes in procedures, and any incidents from the past year. Document review date and changes made.
29 CFR 1910.1030(d)(1)

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